FAQs About Cadmium In Fertilizer: Fertilizer Laws And Limits

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FAQs About Cadmiumin Fertilizer:Fertilizer Laws and LimitsWhy do we need limits on cadmium in fertilizer?Cadmium, a naturally present metal, is known tobuild up in and have adverse effects on the humanbody. In 2010, the World Health Organization (WHO)indicated that a growing segment of the populationhas little to no margin of safety from the adverseeffects of cadmium. The WHO also noted a gradualincrease in cadmium levels in agricultural soils andcrops due to atmospheric deposition of the metalalong with the deliberate application of municipalsewage sludge and phosphate fertilizer.1In the last 15 years, biomedical research has showna strong correlation of cadmium body burden inhumans to adverse health effects. Because correlationdoes not mean causation, research continues on themechanisms that contribute to the role of toxicants inchronic diseases. Nonetheless, research has concludedthat cadmium is a major human toxicant; there isa need to limit exposure from as many sources aspossible.²Although cadmium is used in a variety ofmanufactured products, for most people the primarysource of exposure is food. The natural presence ofcadmium in phosphate rock, which is used to makefertilizer, becomes a problem when plants accumulatethe metal in their biomass. More detail about plantcontamination can be found in another report in thisseries, FAQs About Cadmium in Fertilizer: CadmiumContamination in Plants. Vegetables and grains are themost common sources of fertilizer-derived cadmiumin the diet. Fertilizer runoff into surface waters mayalso contribute to high levels of cadmium in fish andshellfish.Based on the evidence presented in this FAQ reportand the others in the series, we believe that statesneed to adopt more stringent limits that will reduceexposures and prevent adverse health effects. Currentfertilizer manufacturing processes remove very littlecadmium and, in some cases, actually concentrateit.³ However, removing cadmium from fertilizerin processing is the most effective way to reducecadmium in our food.www.pprc.org1

What types of fertilizer limits currently exist?Cadmium in fertilizer—phosphate rock, animalmanures, and land applied municipal sewage sludge(hereafter referred to as biosolids)—is increasinglyregulated in different parts of the world. Initially,cadmium was regulated primarily because of concernsabout the metal leaching from fertilized soil intoground and surface waters. However, as knowledgeincreased about cadmium as a major human toxicantin our food, the emphasis on allowable cadmium infertilizer has shifted to the amount of uptake seen inagricultural commodities grown on soils that includeadded cadmium in fertilizer.The limits on cadmium in fertilizer have taken severalforms, most commonly: A limit on the amount of cadmium allowed perunit of phosphorous (mg Cd/kg P). A limit on the amount of cadmium allowed perunit of phosphorous oxide (mg Cd/kg P2O5).This limit is used because American Plant FoodControl officials have adopted P2O5 as thestandard for guaranteed analysis of phosphorouscontent based on an older measurementtechnique. The method has been replaced, butthe designation is still used to represent thepercentage of phosphorous content of fertilizer(the middle number on a bag of fertilizer) in theUS. This measure may be a bit confusing becausethe actual phosphorous applied to soil is about44 % of the P2O5 weight percentage designatedon the bag. A limit on total cadmium that can be appliedto an agricultural field each year, expressed aspounds Cd per acre or kilograms per hectare (kgCd/ha).A limit based on mg Cd/kg P or mg Cd/kg P2O5generally prohibits the sale and application offertilizer that does not meet that limit in a givenjurisdiction. For states that require registrationand licensing of fertilizers, these limits are easilyenforceable. A limit that mandates a maximum totalamount of Cd that can be applied per year is moreflexible and allows a farmer to adjust the amount ofphosphorous fertilizer applied depending on plantneeds and the cadmium loading in the fertilizer.However, this latter type of limit requires morediligent record keeping than a sales restriction and ismuch much less likely to be enforced.www.pprc.org2

Are fertilizer limitseffective?How do you compare differentlimits and measurements?All types of fertilizer limits can be effective if: a.) They are sufficiently stringent to protect bothpublic health and the environment, the corollaryof which is that they must be reviewed every fewyears and updated when needed based on newinformation; b.) They require metals analysis with detectionlimits that are low enough to be meaningfuland enable people to choose the lowest metalconcentrations, the corollary of which is thatdetection limits should be no greater than 0.1 mgCd/kg fertilizer product. For example, a detectionlimit of 1 ppm Cd in a 2 % P2O5 product will onlyindicate cadmium concentrations greater than 50mg Cd/kg P2O5; c.) They are easily implementable and can bereadily understood both by the industry and thepublic; and d.) They are actively enforced, the corollaryof which is that if the limits are based on totalcadmium applied per unit area, the informationon the cadmium applied for each farm should bereadily available to the enforcing agency and thepublic.Comparing different types of limits is sometimesdifficult and may require conversions between P andP2O5 or back calculating mg Cd/kg P2O5 based onan assumed fertilizer application rate. Phosphorouspentoxide (P2O5) is 44% P (take the Cd/kg P anddivide it by 2.29 to get Cd/kg P2O5).For the purposes of this fact sheet, the cadmium limitsare compared based on the US standard units of mgCd/kg P2O5. For limits based on total annual cadmiumapplied, we assume an annual P2O5 application rate of100 kg per hectare.³ This assumed annual applicationrate is higher than typical for wheat but lower thanthat typical for vegetables; if you apply only halfof the assumed application rate to wheat, the limitwould appear twice as high, and if you apply twice theassumed application rate to vegetables the limit wouldappear only half as high.A further complication arises when trying tocompare the cadmium content listed in state fertilizerdatabases to a cadmium limit based on mg Cd/kgP2O5. The requirement for reporting metals in stateswith fertilizer registration databases is often based onthe amount of cadmium in the product, not per kg ofP2O5. For those interested in comparing the fertilizerthey use to worldwide standards, the conversion mustuse the guaranteed amount of phosphorous (as P2O5)as per standard reporting methods.www.pprc.org3

What are the current limits? .A summary of the limits for cadmium in fertilizersis provided in the table on page 6. A more detailedexplanation of some of the limits and how theydeveloped is provided below. The limits are addressedfrom most stringent (EU) to least stringent (EPABiolsolids).European UnionThe EU and member states have been studyingcadmium exposure for almost two decades and haverecently implemented food safety standards andfertilizer limits that are much more stringent than anystandards existing in the United States. These limitsappear to be based on sound science.Initially, the EU concern about cadmium in food wastriggered by a rising body burden in some segmentsof the population that approached the level of onset ofadverse health effects. In 2000, the average cadmiumlevels in fertilizer and the resulting levels in cultivatedsoil tended to be lower in the countries of northernEurope (about 2.5 mg Cd/kg P in fertilizer and 0.21mg Cd/kg soil) and much higher in other parts ofEurope (about 138 mg Cd/kg P in fertilizer and0.5 mg/kg soil). It was concluded that this averagecadmium content of European fertilizers, 138 mg Cd/kg phosphorous (or 60 mg Cd/kg P2O5), would leadto a radical increase in the concentrations of cadmiumin soil and crops, and in cadmium leaching.The highest impacts, based on average Europeanfertilizer levels of the metal, were estimated at a125% increase in soil concentrations in potato fields,a 34% increase in the concentration in wheat grain,and a 124% increase in cadmium leaching. At theFinnish national limit of 50 mg Cd/kg P (21.5 mg Cd/kg P2O5), the corresponding impacts were estimatedto increase 43%, 12%, and 42% respectively. In 2000,the Finnish Environmental Institute compared theestimated increases to the observed 30% increaseof cadmium in soil over a 13-year period from 1974to 1987, when the cadmium levels in fertilizer werenotably higher (closer to the EU average). Theyconcluded that the noted increases adversely affectedsoil health, aquatic health through leaching, andhuman health through diet. While the overall averagecadmium intake from food alone does not pose a riskto most people in Finland, certain populations areconsidered at higher risk. For example, vegetariansmay consume more of the metal due to their diet,women may increase absorption of the metal dueto low levels of iron, and smokers are exposed to anadditional source of cadmium.4 It should also be notedthat two scenarios evaluated in this assessment -- theEU average cadmium concentration in fertilizer andthe Finnish national limit for cadmium in fertilizer -–may result in lower cadmium exposures than any ofthe existing fertilizer limits in the U.S.In the spring of 2016, the European Commissionproposed a regulation that will phase in increasinglystringent limits of cadmium in fertilizer. Accordingto the proposal, an initial limit of 60 mg Cd/kg P2O5will apply as soon as the regulation comes into force.A more stringent limit of 40 mg Cd/kg P2O5 willphase in three years later, and the lowest limit of20 mg Cd/kg P2O5 will come into force nine yearsafter the initial effective date.5 As of this report’spublication, however, EU member states are still splitregarding their support of the proposed limits and theregulation’s timeline.6CaliforniaCalifornia established non-nutritive standards forcadmium in fertilizer. The standard is set at 4 ppmcadmium for each 1% of P2O5 in the fertilizer.⁶ Forexample, a fertilizer with a guaranteed P2O5 contentof 10% is allowed a concentration limit 10 times 4ppmor 40 ppm; or a fertilizer with a guaranteed P2O5content of 50% is allowed a concentration limit 50times 4 ppm or 200 ppm. These examples translate toan equivalent of 400 mg Cd/kg P2O5. The Californiastandard, the most stringent standard in the US, isfar less (20 times less) protective than the final EUstandard.California requires that fertilizers sold or applied inthe state be registered and licensed. A search of theregistered products may be conducted on the state’sFertilizing Materials Program database.7www.pprc.org4

What are the current limits? continued .OregonOregon also established non-nutritive limits forcadmium in fertilizer. The type of standard is similarto California but less stringent. The limit is set at 7.5ppm cadmium for each one percent of P2O5 in thefertilizer. The allowed concentration is calculated inthe same manner as California. However, for purposesof calculating the maximum allowed concentrationof a metal in the product if the guaranteed P2O5 ina product is less than 6%, the minimum multiplierused is 6. When the fertilizer has no guaranteedanalysis of P2O5 but does have a guaranteed analysisof one micronutrient, the limit is set at 61 ppm foreach percent of the micronutrient. The Oregon limitfor fertilizers containing phosphate translates to anequivalent of 750 mg Cd/kg P2O5.8Oregon requires that fertilizers be registered. Theregistration process includes a requirement forsubmitting a heavy metals laboratory analysis report.The detection limit required for cadmium is 5 ppm(this detection limit is, in our opinion, too high toevaluate potential exposures). More information maybe found on the state’s registered product database.WashingtonWashington regulates cadmium in fertilizer underthe Washington Fertilizer Law, Revised Code ofWashington, Chapter 15, Section 54. Standards havebeen established for allowable levels of nonnutritivesubstances in commercial substances. The codeadopts Canadian standards: “These standards areCanadian figures for agricultural and agri-foodCanadian maximum acceptable metal additions to soilestablished under Trade Memorandum T-4-93 datedAugust 1996.9“The maximum acceptable cumulative metalsadditions to soil means the amount of total metalsthat can be added to soil over a forty-five-year periodof time without exceeding the Canadian standards ” ⁹The maximum application rate of cadmium is 0.079lbs Cd/year. Waste-derived and micronutrientfertilizers must be tested by the Toxicity CharacteristicLeaching Procedure (TCLP) method, whichdetermines levels of hazardous waste. As measuredby TCLP, the Maximum Allowable Metals Standard forcadmium is 1.0 ppm. Washington also requires thatfertilizers be registered. As part of the registrationprocess, fertilizer registrants are required to submitinformation regarding the levels of metal in each oftheir fertilizer products. Metals are reported in mg/kg of fertilizer (ppm). More information may be foundon the state’s Department of Agriculture ProductDatabase.As with Oregon, Washington’s loose limit on cadmiumapplication (0.079 lbs Cd/yr) translates to anequivalent of about 889 mg Cd/kg P2O5.EPA Biosolids LimitsThe EPA limits on cadmium and other metals forthe land application of biosolids are quite high whencompared to chemical fertilizer limits, but the actualamount of phosphorous in biosolids is variable andrelatively low compared to chemical fertilizer. TheEPA considers land application of biosolids a recyclingmethod and allows use of biosolids as a fertilizeror soil amendment for conventional farming. TheNational Organic Standards Program, however,precludes the use of biosolids for organic farming.www.pprc.org5

What are the current limits?continuedTable 2.1 Restrictions on Cadmium inFertilizers 3JurisdictionsLimit in mg Cdper kg P2O5Netherlands17.5European Union60 40 ustralia131Japan148California*400 (by rule4 ppm per %)750 (by rule7.5 per %)889 (by rule0.079 lbs/acre)889 (by rule0.079 lbs/acre)1.9 kg Cd/haOregon*Washington**Canada**US EPA (biosolids)****These limits are 2.29 times higher than the numberscited in the table presented by Roberts in Cadmium andPhosphorus Fertilizers: The Issues and the Science. Theadministrative rules for both CA and OR indicate limitsof 4 ppm & 7.5 ppm respectively, per 1% guaranteedP2O5 rather than P.**The allowable limit in the rule is total cadmium thatcan be applied to agricultural fields per year.***The EPA limit is for the land application of biosolidsused for fertilizer and/or soil amendment on agriculturalland, the EPA does not limit Cd in fertilizer.www.pprc.org6

Why are limits so different between countries and states?Differences in cadmium limits are difficult to explainbecause they imply unequal protectiveness fordifferent populations. Varying growing conditionscan explain part of the variety of limits, but realdifferences in regulation appear due to differences inregulatory philosophy.Europe, both the EU and the member states, placesa high value on human health and quality of lifefor everyone. A philosophy of prevention guidesprotection of public health and the environment.The EU monitors health, including measuring thebody burden of toxics as an indicator of health,and it creates laws based on these indicators. Therulemaking process incorporates rigorous riskassessments accompanied by a thorough analysis ofmonitoring data along with implementation of the“Precautionary Principle” for unknowns. The cost forprotectiveness may be reflected in the price of theproduct—as the price of fertilizer across the EU couldbecome more expensive than in the US—but the longterm health benefits, and associated cost savings,should outweigh the additional cost of fertilizer.In contrast, the US has not regulated toxics in anequally meaningful way. This is true even whensubstances and chemicals have been demonstratedto be harmful and when exposure can be prevented.States often regulate the easy issues (e.g., cadmiumin children’s jewelry) while ignoring real exposuredriven issues (e.g., cadmium in baby food or teethingbiscuits that come from fertilizer. See the FDA’s TotalDiet Study for listings of cadmium measures in foodproducts).If as a nation we value profit maximization overadopting precautionary practices, then our nation’shealth will suffer. The long-term cost of caringfor those who develop disease from preventableexposures is likely to continue to escalate.The California Office of Environmental Health HazardAssessment (OEHHA) is well known for the qualityand rigor of its risk assessments of toxic materials.The state’s Proposition 65 law may warn rather thanrestrict, but the Proposition 65 safe harbor level (themaximum allowable dose for reproductive toxicity)for cadmium is 4.1 μg/day (oral).11 Although theCalifornia limits on cadmium in fertilizer are morerestrictive than other states, these limits remainunlikely to achieve the safe harbor level for cadmium.Regulations in other parts of the world tend to fallsomewhere between the more protective levels of theEU and the less protective levels of the United States.Japan is a notable exception. Although the country hasexperienced some notable toxic incidents involvingcadmium, the government quickly investigatedand reacted to prevent reoccurrence. China, on theother hand, suffers from serious soil contamination,mostly from industrial pollution, that is affecting thecountry’s food. Cadmium contamination is becomingan increasingly acute health concern in China.Because the US lacks the capacity to produce organicfoodstuffs to meet the rising demand, the US importsorganic vegetables from China.12www.pprc.org7

Are limits protectiveof human health?If limits aren’t adequate,how do we change them?The answer to that question for the US in general,and the Northwest in particular, is likely no. Severalstrong indicators explain why: The body burden of cadmium in limited samplesin Washington (measured by the WashingtonDepartment of Health) is higher than thecountry’s average, which in turn is higher thanthe EU average. No data exist for other states inthe Northwest. In the US, the body burden of cadmium invegetarians, or the population that eats the mostvegetables, is second only to smokers.14, 15 Cadmium in food, especially vegetables andgrains, is not only common but often above foodsafety limits (see another report in this series,FAQs About Cadmium in Fertilizer: CadmiumContamination in Plants) and advisory intakelevels. The Washington Department of Ecologyestimated that 27% of the annual loading ofcadmium in Puget Sound occurs via irrigationrunoff from cadmium in fertilizer. This is notan issue only for Puget Sound but for all surfacewater.16 Health effect studies continue to inform us aboutthe harmful levels of cadmium in our bodies.PPRC has broadly considered a number of options forreducing cadmium exposures by limiting cadmium infood. Our preliminary conclusion is that the best wayto manage long-term cost is by removing cadmiumat the source, namely in fertilizer used for crops.Reducing exposure could also be done by establishingstringent food safety limits. But this would requirestrict monitoring for food safety limits and would besignificantly more expensive.To change the limits, which have been created byboth statute and regulation, will be a lengthy process,but not an impossible one. It takes a village, so tospeak, and this village includes scientists, consumers,regulators, the regulated community, and legislators(in this case, mostly at the state level). The first step iseducating people at all levels and demonstrating whychange is needed. The EU has done a lot of that workfor us and has taken more than a decade gatheringconsensus. Because the EU pioneered the way, thepath toward more responsible limits should be easierin the US unless the regulated community pushesback by saying that work done in Europe does notapply to America. Many multinational companies areused to working with European data and regulations,but the agriculture community tends to favor auniquely American approach. Such an insular attitudecould severely hurt regulation progress becauserepeating the work already done well by the EU couldtake the US at least a decade.At a time when protections of health and theenvironment are poorly funded, gathering andanalyzing the available information, as PPRC hasdone, is a good place to begin. However, makinglegislative changes will require support fromeveryone, especially from local communities, but alsofrom environmental and health activist organizations,tribal fisheries, organic producers, farm serviceagencies, and Agricultural Extension Offices.www.pprc.org8

How can I help?ConclusionEvery individual can help: 1.) Learn more about cadmium in fertilizer andfood and tell your friends (contact PPRC if youhave questions). 2.) Talk to your produce manager aboutcadmium in fertilizer and food. State yourpreference for low to no measurable cadmiumand encourage stores to buy from growerswilling to certify low cadmium. Customers canmotivate retailers, and retailers can motivateproducers. 3.) Talk to your local farm service agencies andhelp educate them on cadmium. 4.) Talk to your political representatives and askthem to support adopting new cadmium limitsfor fertilizer following the EU. Please feel freeto use this FAQ report as well as others in thisseries. 5.) To the extent that you can, grow your ownvegetables using very low (less than 20 mgCd/kg P2O5) cadmium fertilizer. Note thatthis number is different than the numbers inthe online fertilizer databases from Oregonand Washington that are based on cadmiumper weight of the whole product. For help inunderstanding and translating the numbers,please call PPRC at 206-352-2050 or a localAgriculture Extension Office.Current limits on cadmium on fertilizers in the USare insufficient to meet health and environmentalprotection goals. The states that have previouslyestablished limits need to review recent researchon the health effects of cadmium, the buildup ofcadmium in soils, and the contribution of fertilizerto cadmium loading in surface waters. These statesshould lead the way toward health protection byby adopting more stringent limits that will reduceexposures and prevent adverse health effects. DisclaimerThis series of fact sheets on cadmium in fertilizer is notintended to discourage growing or eating vegetables.Vegetables are critical to life; the healthiest and tastiestones often come from gardens. The information presentedhere is intended to help provide a better understanding ofcadmium, how it gets into our food supply, how it can affectour health, and how we can minimize our exposure.Writing CreditsResearch and writing by: Marjorie MartzEmersonEdited by: Cyrus PhilbrickAdditional data analysis provided by: Michelle Gaither* For more information on cadmium and other heavy metals, visit www.pprc.orgwww.pprc.org9

References1. World Health Organization, Preventing Disease through Healthy Environments, Exposure to Cadmium: A MajorPublic Health Concern. 2010.2. Mead, M.N., Cadmium Confusion: Do Customers Need Protection. Environmental Health Perspectives, 118(12),p. A528-A534, December, 2010.3. Roberts, T.L., Cadmium and Phosphorus Fertilizers: The Issues and the Science. 2nd International Symposiumon Innovation and Technology in the Phosphate Industry, Procedia Engineering, 83, p 52-59, 2014.4. Finnish Environmental Institute, Cadmium in Fertilizers, Risks to Human Health and the Environment:Study Report for the Finnish Ministry of Agriculture and Forestry. October, 2000. [online] iles/reports/finland en.pdf5. Rojo, J., MEPs vote for faster cadmium phase-down in fertilisers. ENDS Europe, May 31, 2017.6. Rojo, J., Member states split on limiting cadmium in fertilisers. ENDS Europe. July 5, 2017.7. California Code of Regulations, Title 3, Division 4, 2302. [currently not available online]8. Oregon Administrative Rules, Department of Agriculture. 603-059-0020 [online] http://arcweb.sos.state.or.us/pages/rules/oars 600/oar 603/603 059.html9. Revised Code of Washington, Chapter 15-54. [online] http://app.leg.wa.gov/RCW/default.aspx?cite 15.5410. Washington Administrative Code, 16-200-695. [online] http://apps.leg.wa.gov/WAC/default.aspx?cite 16-200-69511. California Office of Environmental Health Hazard Assessment, Proposition 65 No Significant RiskLevels (NRSLs) for Carcinogens and Maximum Allowable Dose Levels (MADLs) for Chemicals CausingReproductive Toxicity. May 17, 2017. [online] 5/p65safeharborlevels040116v2.pdf12. The most neglected threat to public health in China is toxic soil. The Economist. June 8, 2017. [online] d-threatpublic-health-china13. Food and Drug Administration, Total Diet Study: Elements Results Summary Statistics Market Baskets 2006through 2013. 2014. [online] ucm184301.pdf14. Krajčovičová-Kudláčková, M. et al., Cadmium Blood Concentrations in Relation to Nutrition. Central EuropeJournal of Public Health. 14(3); 126-129. 2006.15. Järup, L. et al., Health effects of cadmium exposure – a review of the literature and a risk estimate.Scandinavian Journal of Work, Environment & Health. 24(1): 1-51. 1998.16. Norton, D., et al., Control of Toxic Chemicals in Puget Sound: Assessment of Selected Toxic Chemicals in thePuget Sound Basin, 2007-2011. Department of Ecology, Publication No. 11-03-055. 2012.2101 Fourth Ave. Suite 1089Seattle, WA98121www.pprc.org10

with fertilizer registration databases is often based on the amount of cadmium in the product, not per kg of . Oregon Oregon also established non-nutritive limits for cadmium in fertilizer. The type of standard is similar to California but less stringent. The limit is set at 7.5

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